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Daniel Felz

CISA and JCDC Conduct First-Ever Public-Private AI Security Incident Tabletop Exercise

August 6, 2024 By Daniel Felz and Kim Peretti

On June 13, 2024, the Cybersecurity and Infrastructure Security Agency (CISA) collaborated with the Joint Cyber Defense Collaborative (JCDC) to hold the federal government’s first tabletop exercise for “AI security incidents.  JCDC led the exercise and, true to JCDC’s public-private partnership model, included over 50 participants from various government agencies and private-sector companies. For those […]

Filed Under: AI, Artificial Intelligence, Cyber Risk, Cybercrime, Cybersecurity, Security Breach, Uncategorized Tagged With: AI, Artificial Intelligence, CISA, Cybersecurity

Article: White Paper on Clarifying Definitions in the Protecting Americans’ Data from Foreign Adversaries Act of 2024

June 12, 2024 By Daniel Felz and Santi Villar

Peter Swire, Senior Counsel at Alston & Bird, has published a white paper at the Cross-Border Data Forum (“CBDF”), analyzing the definitions in the Protecting Americans’ Data from Foreign Adversaries Act of 2024 (“PADFAA”), which was passed on April 24, 2024 and will take effect on June 23, 2024. The white paper discusses some ambiguities […]

Filed Under: Data Protection, Legislation, National Security Tagged With: Cross-border, Data Protection, International Data Transfers

Data Breach Notification Requirements under the Safeguards Rule Now in Effect

June 11, 2024 By Daniel Felz and Dorian Simmons

For years, the Gramm-Leach-Bliley Act (GLBA) has required financial institutions to maintain reasonable safeguards for consumer data, but has only had limited breach-reporting requirements. To the extent financial institutions were subject to breach-reporting obligations, these were set by non-GLBA legislation, such as state law, or by relatively narrow incident-reporting rules under Interagency Guidelines overseen by […]

Filed Under: Cybersecurity, Data Breach, Data Breach Litigation, Data Protection, Data Security, Enforcement, FTC, Security Breach

China Releases Updated Regulations on Permits Needed for Transferring Data out of China

April 2, 2024 By Daniel Felz and Yin Tydir

On March 22, 2024, the Cyberspace Administration of China (CAC) published the Regulations on Promoting and Regulating Cross-border Data Flow (the “Regulations”), effective immediately. The Regulations supplement China data protection laws (the Cybersecurity Law, the Data Security Law, and the Personal Information Protection Law), and take precedence over previously-issued data transfer rules, such as (a) […]

Filed Under: China, Data Protection, International, Regulation, Transfers Tagged With: Cross-border, International Data Transfers

More Guidance from HHS on Online Tracking Technologies but Questions Remain

March 20, 2024 By Daniel Felz, David Keating and Sara Pullen Guercio

Health and Human Services (“HHS”) released updated guidance yesterday on the use of online tracking technologies (like cookies, pixels, software development kits (SDKs), etc.) by HIPAA Covered Entities (the “Updated Guidance”). The Updated Guidance amends and supersedes HHS’s original guidance on the use of digital tracking technologies published on December 1, 2022 (the “Prior Guidance”).  […]

Filed Under: Data Breach, Data Breach Litigation, Data Security, Enforcement, ePrivacy, Health Privacy, HHS, Mobile Privacy, Online Privacy, Privacy, Privacy Litigation, Regulation

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